ENFORCEMENT IS REAL

AUSTRAC Is Actively Enforcing — And Pubs & Clubs Are on the Radar

The days of AML/CTF being a paperwork exercise are over. Here’s what recent penalties mean for your venue.

The Numbers Speak for Themselves

$450M
Crown Resorts — 2023
$67M
SkyCity Adelaide — 2024
$33M
Maximum penalty per contravention (from March 2026)

These aren’t theoretical numbers. These are penalties that have been ordered and paid. And the trend is clear: AUSTRAC is enforcing harder, with bigger penalties, and expanding its focus beyond casinos.

Crown Resorts — $450 Million

What happened

Crown Resorts was found to have systematic and sustained failures across its Melbourne, Perth, and Sydney properties. The Federal Court found Crown failed to:

  • Properly monitor transactions for suspicious activity
  • Conduct adequate customer due diligence on high-risk customers
  • File suspicious matter reports when required
  • Maintain an effective AML/CTF program

The $450 million penalty was the largest in AUSTRAC’s history at the time.

SkyCity Adelaide — $67 Million

What happened

SkyCity was penalised for failing to properly manage ML/TF risks in its Adelaide casino. Key failures included:

  • Inadequate transaction monitoring systems
  • Poor risk assessment of customers
  • Failure to report suspicious matters in a timely manner
  • Insufficient staff training on AML/CTF obligations

Mounties Club — Proceedings Underway

This one’s for pubs and clubs.
Mounties (Mount Pritchard and District Community Club) is currently facing proceedings for alleged systematic non-compliance. This is a community club — not a casino. AUSTRAC is demonstrating that enforcement applies to all reporting entities, regardless of size.

“We’re Just a Small Pub” — Why That’s Not a Defence

A common misconception in the industry is that AUSTRAC only targets large casinos. That’s wrong, and the Mounties case proves it.

AUSTRAC CEO Brendan Thomas has been explicit: gambling remains “at the frontline” of AML regulation. He’s identified specific risks in pubs and clubs:

  • High-value/high-frequency cash transactions with limited monitoring
  • “Bill-stuffing” — large amounts of cash inserted into gaming machines with minimal gameplay, then withdrawn as apparently legitimate winnings
  • Manual observation by staff as the primary monitoring method, rather than structured risk-based systems
“Preparation is expected, perfection is not — but where risks remain unmanaged, regulatory action will follow.”
— Brendan Thomas, AUSTRAC CEO

AUSTRAC’s Enforcement Toolkit

From 31 March 2026, AUSTRAC has expanded enforcement powers:

Civil penalty orders

Up to $33 million per contravention for corporations. That’s per contravention — multiple breaches mean multiple penalties.

Remedial directions

AUSTRAC can direct you to fix specific issues. Non-compliance with a remedial direction can result in gaming operations being restricted or shut down.

Enforceable undertakings

Legally binding agreements requiring your venue to take specific remediation actions within set timeframes.

Infringement notices

For minor breaches — a formal warning without court proceedings. Still goes on your record.

Criminal sanctions

Up to 10 years imprisonment for serious offences, including tipping off (disclosing the existence of an SMR).

What Gets Venues in Trouble

Based on AUSTRAC’s published enforcement actions and guidance, the most common failures are:

  1. No AML/CTF program or a program that’s never been reviewed
  2. No transaction monitoring — relying solely on staff observation
  3. Failure to file SMRs when suspicious activity was evident
  4. No customer identification for payouts above the threshold
  5. No staff training or training that hasn’t been updated
  6. No risk assessment or a risk assessment that doesn’t reflect actual business risks

How to Protect Your Venue

  • Have a current, reviewed AML/CTF program that reflects your actual risks
  • Monitor transactions systematically — not just by staff observation
  • File SMRs when required — within 3 business days (24 hours for TF)
  • Train your staff regularly and keep records of training
  • Document everything — if it’s not documented, it didn’t happen
  • Appoint a fit and proper compliance officer by 30 May 2026
AUSTRAC’s message is clear:
They’re not expecting perfection. They’re expecting preparation. If you can demonstrate that you’ve identified your risks, implemented reasonable controls, and trained your staff, you’re in a strong position. If you’ve done nothing — you’re a target.

References

  1. AUSTRAC, Consequences of not complying — austrac.gov.au
  2. AUSTRAC, Regulatory Expectations and Priorities 2025–26 — austrac.gov.au
  3. Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) — Parliament of Australia
  4. SBC News, AUSTRAC CEO on AML/CTF Reforms — sbcnews.co.uk

Get compliant before AUSTRAC comes knocking

ComplyIQ gives your venue transaction monitoring, SMR management, risk assessment, and staff training — all in one platform built for pubs and clubs.

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